What is GS1 Digital Link and do I need it for the digital product passport?

A technical standard for the QR code, not a separate legal obligation

GS1 Digital Link is a way to structure a barcode or QR code so that it can do two things at once: identify a product (the way a regular barcode already does) and immediately direct to a web page with more information about that product. The code then contains, for example, the GTIN number of the mattress, embedded in a regular internet link. A checkout scanner reads the code as usual, but a consumer or buyer who scans the same code with a phone arrives at a web page — in this case the digital product passport. GS1 Digital Link is not itself an obligation under the ESPR; it is an existing, globally used standard that aligns well with what the ESPR requires of the product passport: a unique identification (Article 12) that is accessible via a machine-readable carrier (Article 11).

For whom this is relevant, and for what it is not

This topic is particularly relevant for manufacturers and importers who have the QR code created on the mattress or packaging, and parties who already work with GS1 numbering for logistics or retail (GTIN, GLN). For bed specialist retailers and hotel purchasing, it is mainly relevant as background: they scan the code, but do not need to set anything up themselves. GS1 Digital Link concerns the form of the data carrier — how the code is structured so that it points to the right place. It says nothing about the content of the passport: which data must be included in it, who supplies them and how long they are kept, follows from other parts of the ESPR and from the product-specific delegated act for mattresses. Also, GS1 Digital Link is not the only way to comply with Article 11; the ESPR text available here does not prescribe a specific technical standard. GS1 Digital Link is currently the standard most commonly used in practice for this type of application, among other things because many manufacturers already use GS1 numbers for their existing barcodes.

When this becomes concrete is still uncertain

The date on which a product passport for mattresses becomes mandatory is not yet fixed. That date will only become clear once the delegated act for mattresses has been published; at present this has not yet happened. What is fixed is the framework from the ESPR itself: Article 11 determines that the passport must be accessible via a data carrier and Article 12 that a unique identification code must be linked to the product. The precise technical implementation — what type of data carrier, what syntax, and whether a standard such as GS1 Digital Link is mentioned by name — is something that belongs in the implementation details of the delegated act, and these do not yet exist for mattresses. Until then, there is room to align with an existing, widely supported standard without there being a legal obligation to use that specific standard.

How this works in practice for a manufacturer

If you're already thinking about the QR code on a mattress, you usually start with the question of whether GS1 numbers are already in use for logistics or sales — a GTIN on the packaging, for example. If so, the step to GS1 Digital Link is relatively small: the same number is then processed in a link structure that points to the passport instead of only to a product description. If there is no GS1 numbering in use yet, the first step is usually to request a GS1 company prefix from GS1 Nederland (or the local GS1 organisation), after which GTINs can be issued per mattress model or variant. This is followed by the choice of what exactly is behind the link: it is the passport itself, with the data that the manufacturer provides. Matrapas.eu handles the formatting of the passport and the QR data carrier in that final step, but the GTIN and any GS1 registration remain with the manufacturer or importer themselves, because they may already have a basis for this from existing sales channels.

Based on: Article 11 and Article 12 of the ESPR

Article 11 of Regulation (EU) 2024/1781 governs the technical design and operation of the digital product passport, including the requirement that the passport must be accessible via a data carrier. Article 12 governs the unique identification code that is linked to the product. Both articles describe what the passport must be capable of, not with which specific technical standard that is realised. GS1 Digital Link is an existing standard that meets those two requirements, but the articles themselves do not mention that standard by name.

What to do

If you are already producing or importing mattresses and are already working with GS1 numbering, you can get that basis in order now: a valid GTIN per model is the first building block for a QR code that can later point to a passport. If you don't have that yet, you can include the application for a GS1 company prefix as a preparation step, without having to wait for the publication of the delegated act for mattresses. For the content of the passport itself and the exact mandatory data, the official text of the ESPR and the delegated act to be published remain the source to follow.